28(1)The Board may by notice in writing require a person—U.K.
(a)to deliver to a named officer of the Board such documents as are in the person’s possession or power and (in the Board’s reasonable opinion) contain, or may contain, information relevant to—
(i)any tax liability to which the person is or may be subject, or
(ii)the amount of any such liability, or
(b)to provide to a named officer of the Board such information as the Board may reasonably require as being relevant to, or to the amount of, any such liability.
(2)Notice under this paragraph shall not be given unless the Board have reasonable grounds for believing—
(a)that the person to whom it relates may have failed, or may fail, to comply with any provision of this Part of this Act, and
(b)that any such failure is likely to have led, or to lead, to serious prejudice to the proper assessment or collection of tax.